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Section 147

Latest Articles


Addition Deleted Due to Lack of Corroborative Evidence in Search-Based Case

Income Tax : ITAT held that additions based solely on third-party search material without independent evidence or cross-examination are invalid...

April 21, 2026 507 Views 0 comment Print

Sections 147 & 148 of Income-Tax Act: Reassessment From ‘Reason to Believe’ to ‘Information’

Income Tax : A detailed look at how the Finance Act, 2021 reshaped Sections 147–151, introduced Section 148A, and reduced limitation periods ...

February 28, 2026 873 Views 0 comment Print

Jurisdiction for Reassessment Notices Clarified to End Faceless AO Disputes

Income Tax : The Finance Bill, 2026 clarifies who can issue notices under sections 148 and 148A. It confirms that only jurisdictional Assessing...

February 2, 2026 2844 Views 0 comment Print

Can Penalty be Levied on Delayed Annual GST Return?

Goods and Services Tax : The court held that once late fee is imposed for delayed annual return filing, a further general penalty is not permissible. Secti...

January 20, 2026 18258 Views 2 comments Print

Reassessment Quashed as Limitation Ran From Original Assessment, Not Revision

Income Tax : The issue was whether an assessment could be reopened after four years. The Court held that full disclosure by the taxpayer barred...

January 8, 2026 423 Views 0 comment Print


Latest News


Budget 2024: Block Assessment provisions for Section 132 & 132A Searches

Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...

July 23, 2024 2193 Views 0 comment Print

Budget 2024: Amendments to Income-tax Assessment & Reassessment Provisions  

Income Tax : Discover how Finance Act 2021 revamped assessment and reassessment procedures under Income-tax Act, impacting notices, time limits...

July 23, 2024 4314 Views 0 comment Print

Request to clarify on SC judgement on Section 148 notices

Income Tax : Income Tax Gazetted Officers’ Association requested CBDT to issue Clarification in respect of the judgement of Hon’ble Supreme...

May 12, 2022 7458 Views 0 comment Print

Indiscriminate Income Tax notices without allowing reasonable time

Income Tax : In view of Indiscriminate notices by income Tax Department without allowing reasonable time it is requested to Finance Ministry an...

March 20, 2022 13332 Views 0 comment Print

Extend Time Limit for Income Tax Assessment time barring on 31.3.2022

Income Tax : Lucknow CA Tax Practicioners Association has made a Representation to FM for Extension of Time Limit for Assessment cases time bar...

March 20, 2022 42774 Views 2 comments Print


Latest Judiciary


Section 68 Additions: Favourable Remand Report Shields Assessee

Income Tax : The issue was deletion of additions on unsecured loans treated as unexplained cash credits. The tribunal upheld deletion, holding ...

May 2, 2026 81 Views 0 comment Print

Delay Condoned with Cost: ITAT Grants Fresh Chance, Slams Non-Compliance

Income Tax : The issue involved dismissal of appeal due to delay and non-appearance. The tribunal condoned the delay citing medical reasons and...

May 2, 2026 108 Views 0 comment Print

Reassessment After 4 Years Quashed as No Failure to Disclose Material Facts: Bombay HC

Income Tax : The issue was whether reassessment could be initiated after four years without fresh evidence. The court held such reopening inval...

May 2, 2026 99 Views 0 comment Print

Reassessment Quashed for Wrong Sanction: ITAT Bangalore Strikes Down 147 Order for Breach of Section 151

Income Tax : The issue was whether reassessment notice issued without approval from the correct authority is valid. The tribunal held it invali...

May 2, 2026 90 Views 0 comment Print

Reassessment Notice Time-Barred as Issued Beyond Limitation Period: Karnataka HC

Income Tax : The Court held that reassessment proceedings must be initiated within the statutory time limit. It found the notice issued after t...

May 1, 2026 453 Views 0 comment Print


Latest Notifications


ITO doesn’t have jurisdiction to issue notice to NRI: ITAT Chandigarh

Income Tax : ITAT Chandigarh held that ITO Ward-3(1), Chandigarh had no jurisdiction to issue notice to an NRI and hence consequently the asses...

April 11, 2025 5742 Views 0 comment Print

Central Government Rescinds 6 Central Excise Notifications issued in 2022

Excise Duty : Notification No. 29/2024-Central Excise rescinds six 2022 excise notifications in the public interest, effective immediately. Deta...

December 2, 2024 813 Views 0 comment Print

Instructions to AO’s for initiating section 147 proceedings in I.T. e-Verification cases

Income Tax : Learn how to initiate proceedings under section 147 of the IT Act in e-Verification cases. Detailed instructions for Assessing Off...

March 19, 2024 10272 Views 0 comment Print

Instructions to AO’s for initiating Section 147 proceedings in e-Verification cases

Income Tax : Explore e-Verification Instruction No. 2 of 2024 from the Directorate of Income Tax (Systems). Detailed guidelines for AOs under I...

March 1, 2024 5784 Views 0 comment Print

Limitation date for reopening cases related to Ashish Agarwal judgment

Income Tax : Supreme Court in the matter of Shri Ashish Agarwal, several representations were received asking for time-barring date of such cas...

February 6, 2023 5880 Views 0 comment Print


Bogus Purchase, Loan Creditor Additions Deleted – CIT(A) Relief Upheld

February 13, 2026 888 Views 0 comment Print

The Tribunal found no infirmity in the CIT(A)s detailed order deleting additions based on proper verification of evidence. All grounds raised by Revenue were rejected, and cross-objection became infructuous.

Reassessment Quashed – Notice U/s 148 Issued Before Approval & Mechanical Sanction U/s 151

February 13, 2026 621 Views 0 comment Print

ITAT Delhi held that notice under Section 148 issued before obtaining mandatory approval under Section 151 is invalid. Since sanction was granted after issuance of notice, the reassessment was declared void ab initio.

Reopening Upheld but Addition Restored – Non-Speaking Order on Cost of Improvement

February 13, 2026 330 Views 0 comment Print

The Tribunal confirmed the jurisdictional validity of reassessment based on new information. However, the addition was restored to ensure compliance with principles of natural justice and Section 250(6).

Penalty U/s 271(1)(c) Deleted — Defective Notice U/s 274 Without Specific Charge Invalidates Penalty: ITAT Mumbai

February 13, 2026 324 Views 0 comment Print

The Tribunal held that failure to indicate the precise charge in a Section 274 notice renders penalty proceedings unsustainable. Following jurisdictional High Court rulings, the penalty was set aside.

Reassessment Quashed — Approval by Wrong Authority U/s 151(ii) Invalidates Notice u/s 148 Entire Proceedings: ITAT Mumbai

February 13, 2026 1110 Views 0 comment Print

Relying on Supreme Court and Bombay High Court rulings, the Tribunal ruled that sanction by an incorrect authority vitiates jurisdiction. The reassessment proceedings were set aside for non-compliance with Section 151.

Repaid Advance via Banking Channel Not Cash Credit: ITAT Kolkata

February 13, 2026 456 Views 0 comment Print

The Tribunal found that advances of ₹50 lakh each were duly recorded, confirmed, and repaid. With no unexplained credit involved, the addition of ₹90 lakh was deleted and the appeal allowed.

ITAT Pune Allows Section 54B Exemption Despite Delay in Registration of Agricultural Land

February 12, 2026 951 Views 0 comment Print

Observing that the assessee invested the entire share of sale proceeds within two years and obtained possession, ITAT Pune allowed Section 54B exemption. The addition under Section 69A was consequently deleted.

Commission income earned by Booking.com not taxable in India

February 12, 2026 720 Views 0 comment Print

Booking.com platform earning of commission income is not taxable in India since AO has failed to discharge the onus of establishing assessee having fixed place PE in India. Accordingly, final assessment order is liable to be set aside.

ITAT Allows Earlier Indexation Year Because Possession & Payment Occurred Before Registration

February 12, 2026 615 Views 0 comment Print

The Tribunal held that year of acquisition is determined by payment and handing over of possession under Section 2(47)(v), not by later registration date. Earlier CII was allowed for capital gains computation.

ITAT Bangalore : CIT(A) Has No Power to Set Aside & Remand Assessment (Non-144 Cases) – Matter Restored to CIT(A) for Decision on Merits

February 12, 2026 468 Views 0 comment Print

The Tribunal held that the appellate authority exceeded jurisdiction by restoring the matter to the Assessing Officer for fresh assessment. It directed the CIT(A) to decide the deemed dividend addition on merits as raised in appeal.

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